In Kiobel v. Royal Dutch Petroleum Co., No. 10-1491 (U.S. Apr. 17, 2013), the U.S. Supreme Court held that the presumption against extraterritoriality applies to claims under the Alien Tort Statute (ATS). Consequently, there is no federal court jurisdiction under the ATS for torts in violation of the law of nations that occur in a foreign country.
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